Right to counsel

While a state may have many statutes, court decisions, or court rules governing
appointment of counsel for a particular subject area, a "Key Development" is a
statute/decision/rule that prevails over the others (example: a state high court
decision finding a categorical right to counsel in guardianships cases takes
precedence over a statute saying appointment in guardianship cases is
discretionary).

Legislation, Termination of Parental Rights (Private) - Birth Parents

In In re McClure, 549 N.E.2d 392 (Ind. App. 1990), the court of appeals extended the reach of § 31-35-1-12 to private adoptions, emphasizing that

While there is no express statutory provision requiring appointed counsel in adoption proceedings, an order granting a petition for adoption does indeed terminate a parent's rights ... we must conclude the legislature impliedly intended that any proceeding that terminates a right so fundamental requires the right to counsel as contemplated by the termination statute. Such a right can not be washed away by a tide of indifference to legislative intent.

If "yes",
the established right to counsel or
discretionary appointment of counsel
is
limited
in some way, including any of: the only authority
is a
lower/intermediate court decision or a city council,
not a high court or state legislature; there
has been
a subsequent case that
has
cast doubt; a statute
is
ambiguous; or the right or discretionary appointment
is not
for all types of individuals or proceedings
within that category.